Company Policies

Immersive Digital Sdn Bhd is committed to maintaining high standards of integrity, ethical conduct, workplace safety, and data protection. These policies align with Malaysian regulatory requirements including the Personal Data Protection Act (PDPA) 2010 and Occupational Safety and Health (OSH) practices.

1. Code of Conduct

1.1 Purpose and Scope

This Code defines the standards of behaviour expected from all directors, management, employees, contractors, and representatives acting on behalf of the Company.

1.2 Responsibility and Compliance

Compliance with this Code is mandatory. Any breach or suspected breach must be reported to the Head of Department or Human Resource. Non-compliance may result in disciplinary action including termination and legal proceedings.

1.3 Workplace Conduct

• Professional behaviour based on integrity, honesty, and accountability
• Zero tolerance towards harassment, discrimination, and misconduct
• Compliance with workplace safety procedures and reporting of unsafe conditions
• Performance of duties free from the influence of drugs or alcohol

1.4 Company Assets and Information

Company assets, systems, and data must be safeguarded against misuse, loss, or unauthorised access. All confidential and personal data must be handled securely.

1.5 Data Protection

All personal data is processed in accordance with PDPA 2010 principles, including secure storage, controlled access, and proper handling.

1.6 Conflict of Interest

Situations involving personal interest that may conflict with Company interest must be disclosed and managed appropriately.

1.7 Gifts and Hospitality

• Permitted: modest and reasonable business hospitality
• Prohibited: cash, excessive gifts, or benefits intended to influence decisions

1.8 Digital Conduct

Confidential information must not be disclosed through digital platforms. Public representation requires prior approval.

1.9 Whistleblowing

All personnel are encouraged to report misconduct. Reports are handled confidentially. Retaliation is strictly prohibited.

1.10 Disciplinary Action

Violations may result in warning, suspension, termination, or legal action.

2. Anti-Corruption Policy

2.1 Policy Statement

Immersive Digital Sdn Bhd adopts zero tolerance towards bribery and corruption in all business dealings.

2.2 Scope

This policy applies to employees, directors, agents, vendors, and business partners.

2.3 Prohibited Conduct

• Bribery in any form
• Facilitation payments
• Kickbacks or hidden commissions
• Abuse of authority for personal gain

2.4 Third Party Management

Due diligence must be conducted before engaging vendors or partners. Contracts must include anti-corruption provisions.

2.5 Government Dealings

All dealings with public officials must comply with applicable laws. Improper benefits are strictly prohibited.

2.6 Gifts and Hospitality

All gifts and hospitality must be reasonable, transparent, and properly recorded. Approval is required for high-value items.

2.7 Financial Integrity

All records and transactions must be accurate and complete. False or misleading entries are prohibited.

2.8 Reporting and Enforcement

Any suspected corruption must be reported. Violations will result in disciplinary action and may be referred to the Malaysian Anti-Corruption Commission (MACC).

3. Bribery Incident Response Policy

3.1 Purpose

This policy defines the procedures for handling suspected or confirmed bribery incidents.

3.2 Immediate Action

• Immediate reporting of the incident
• Preservation of evidence and records
• Avoidance of further involvement

3.3 Reporting Channels

Reports must be submitted to Head of Department, Human Resource, or designated Compliance Officer. Anonymous reporting is permitted.

3.4 Investigation Process

• Formal acknowledgement of report
• Assignment of investigation team
• Securing of data and documents
• Confidential interviews and review

3.5 Interim Measures

Measures may include suspension, restriction of access, or freezing of related transactions.

3.6 Outcome

Confirmed misconduct will result in disciplinary action, termination of contracts, and possible reporting to MACC.

3.7 Whistleblower Protection

Whistleblowers are protected from retaliation.

3.8 Corrective Action

Internal controls, policies, and training programmes will be strengthened following any incident.

3.9 Review

Policies are reviewed periodically to ensure continued compliance and effectiveness.